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#2267547 - 03/11/22 07:29 PM Risk Assessment
Jennifer Offline
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Jennifer
Joined: Dec 2014
Posts: 182
Do you include balances of deposits and loans in your BSA/AML Risk Assessment? If so - why? What risk points?

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#2267555 - 03/11/22 08:40 PM Re: Risk Assessment Jennifer
Sunshine Lady Offline
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No, we have never included any balances of deposits or loans in our BSA/AML Risk Assessment.
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#2267583 - 03/13/22 08:23 PM Re: Risk Assessment Jennifer
edAudit Offline
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edAudit
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Yes, in an effort to make the risk assessment quantified. There should also be some determination of why the balances are considered high, medium and low for each category. It may be helpful to detail the balances and number of accounts in each product line.

This would be dependent on your regulator expectations. In NY (downstate) it would be considered a must have.
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#2267596 - 03/14/22 03:50 PM Re: Risk Assessment Jennifer
Curious in Kansas Offline
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Joined: Oct 2015
Posts: 71
No. I've included in my BSA risk assessment a three year historical on the quantity of SARs and CTRs filed along with how many customers have been exempted. Nothing about account balances.

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#2267600 - 03/14/22 04:13 PM Re: Risk Assessment Jennifer
Local_Banker Offline
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Joined: Jun 2019
Posts: 55
Yes, I track deposit and loan balances, along with YOY changes. It can highlight any overall growth in your FI as a whole, or highlight any new products/services that you may want to be aware of.

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#2267657 - 03/15/22 03:32 PM Re: Risk Assessment Jennifer
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We detail products offered but not balances associated with them.

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#2267719 - 03/16/22 01:55 PM Re: Risk Assessment Jennifer
Goldrose Online
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We do include total balance of Loans, Checking accounts and savings accounts at year end, as well as number of customers and how many accounts are business vs personal. These are just part of the numbers we provide, which I will state is on a separate "stats" page, that has our opening summary of the current state of the bank, leadership, number of branches, asset size etc...
Last edited by Goldrose; 03/16/22 01:57 PM.
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#2273315 - 07/23/22 09:58 PM Re: Risk Assessment Jennifer
AML360 Offline
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Joined: Mar 2018
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The volume and value of deposits and loans are relevant to the nature, size and complexity of a bank. This information should be included in the BSA/AML risk assessment. Each product should also be individually assessed.

The remainder of this message has been edited as it was an ad. On BOL, advertisers must contact Tobi Chunowitz to advertise Tobi@bankersonline.com
Last edited by Andy_Z; 07/24/22 02:19 PM.
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#2273816 - 08/04/22 07:42 PM Re: Risk Assessment Jennifer
Questioner Offline
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Joined: Jan 2012
Posts: 113
Did include the balances of deposits and loans in our BSA/Risk RA. I have a question. We used to outsource the BSA/AML RA and the vendor used to include 4 years worth of historical data comparisons. I think 4 years of stats may a bit too much. How many years of historical data do you normally included for the year-over-year comparisons?
Last edited by Questioner; 08/04/22 07:45 PM.
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